In Gribben v. UPS, Gribben, a UPS Driver, complained that UPS failed to provide him an air conditioned vehicle to accommodate his heart condition, in violation of UPS's duty under the ADA to implement reasonable accommodations for disabled employees. The trial court dismissed the complaint because Gribben did not provide any comparative evidence about an average person's ability to work in hot weather, and therefore did not establish that his impairment limited a major life activity. The federal Ninth Circuit Court of Appeals allowed plaintiff to proceed with his ADA claim, holding that Gribben's testimony (that he had trouble breathing and experienced chest pain when working in temperatures above 90 degrees) was sufficient, without further comparative evidence, to require a jury trial of his disability claim.